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Home My WebLink About5 - Proposed modifications to Local Limits for Industrial Pretreatment which may affect discharges fCITYOFBOULDER WATER RESOURC~S ADVISORY ROARD MF,MORANDUM ME~TING DATE: October 20, 2003 TITLE: Staff presentation and WRAB discussion on pioposed modificattons to Local Limits for Industrial Pictiealment which may affecl discharges fioni cerlain commeicial oi mdustrial customers. PRESENT~R: Chris Rudkm - Water Quahty Coordinatoi, Ridge Dorsey- Pretreatment Program, Water Quahty & Env~ronmental Services ~XPCUTIVE SUMMARY: PretieatmenY staff presents this mformational memorandum as an update to Water Resouice Advisory Boaid (WRAB) regaiding the ongomg Local Limits Evaluation The purposc of the Local Limits Evaluation is to develop and piesent proposed modifications to the Boulder City Code goverrung cominercial and mdustrial wastewater discharges to the city ulility system. A more deYailed presentatron and a requasl for fmal approval will be given al the meeting on November 17, 2003. Wastewater generated fiom non-domestic or busmess activrties can contam pollutants which may be harmful to wastewater workers, wastewater treatment opeiations, Bouldei Creek, or limri Biosolids disposal options. City of Boulder's Industrial PreCieatment Program monilors and regulates pollution m Boulder's wastewater Wastewater m Bouldei is geneiaeed fiom three ma~oi eoLUCes; domestic discharges (households, office buildmgs), commercial aclivities (cleaning, dental, photo processmg, automotrve, ctc.), and industnal manufacluimg (circuit boarde, chemicals, food, etc.). AG~NDA IT~M #5 PAGE 1 Wastewater Contributions Millions of gallons per day Ct~~rrent wastewater pollut~tnl control sCrategies include; •.+ Industrial Wastewater Permit Program - Ta~•get pc~llutants include i~iet~.als, toxic oi•ganics, and excess sti•ength w~stewater. This program, implcmented by PreCreaiment Progiam stafl, issue5 wastewater pez•miCs to facilities identified as significant inctustrial use~•s. Tc;cllnically Uased local pollutant liiiiitations are inc.orporated into permit5 along with st~ite and federal pollutant limitaCions. These are tlle li~nits thal are curi•et~~fly being revised by pretceatu~ent staff. • Cori-osion Conlrol - Target polliitant5 include copper, lead. This ~r•ogram, implemented by city drinking wat~r treatment plants, reduces degradation of plumbing pipes aud fixtures througlloul Boulder, • Photo-processors regulation - T~uget poll~rtants include silver. This program, in~plementeci by PreC~-eatmerit Program staff, requires appropriate handling/trealm~nt of silver l~earing fixer solulions. :• Grease trap and sancl tr~ap requii•ement - T~irget pollutants include grease, oil, sand/~rit. This program, implen~entecl hy Development/ Insp~clion Serviccs ~nd 1'retrcatment. Program stai'f, rcyuires appropriate plumbiug devices for restaucants/focxl sci~vice, aul:on~otive shc>ps, and eai-washcs. AGI,NDA 1'1'I?,IVI #5 YAGE 2 •3 Suppoit of City/CounCy Paitneis foi A Clean Envuonment (PACE) Certification progiam - Impleniented by Office of L~nviionmental Affairs and Bouldei Counly Health. PACE implements volunCary certificalion for a numbei of busmess groups such as denusts, restauianYs, pimters, manufacturmg, ete. Code Changes: The proposed modifications serve to• • Comply with state and fedeial regulations requirmg the review and modificarion of local pollutant hmitations governmg lhe dischatge of non-domeshc (mdustrial oi commercial) wastewater to the city of Boulder's wastewater treatment p1anY • Claiify the lcad time requued for the submittal of permit application materials. Fiscal Impacts: Proposed changes m regulato~ y limits will impact permitted significant mdustiial users of the wastewater utility system. Permitted users will be required lo comply wrth potentially more stringent hmrts as desciibed below as well as possibly require the mstallation of additional LrealmenL equipment oi other control mechamsm PieCrealment staff is committed to suppoihng the busmess community through appropiiate environmental iegularion. Pretreatmenl slaff strive to develop and allocate local I~mits lhat are piotective of Boulder's wastewater tieatment plant but do not causc undue hardship on the regulated commumty. Staff recommendation: Thc development oP local lunits is required by state and federal law Failure to do so m accordance with the NaC~onal Pollutant Dischuge Elimmat~on System (NPDES) permit issued to the city wastewater tieatmenl plant would be a violation of tbe federal Clean Water Acl Violattons are sub~ect to enfoicemenl actions by both Coloiado Depattment of Pubhc Health and Environment (CDPHE) and Umted States Env~ronmental Protectton Agency (EPA) agencies. Staff iecommends finahzatton and ~mplementalion of the ongomg local hmiYs evaluation. BACKGROUND: Nationwide requirements for the pictieatment of mdustrial and commercial wastewaCer were estabhshed as a component of the 1972 Clean Watei Act. Subsequent amendments to that aet to protect wastewater tieatment facilities and waterways from discharges of toxic and othei pollutants weie latei enacted All publicly owned lreatment works (POTWs) with design flows gieatei lhan 5 milhon gallons per day were iequned to develop an industrial pretiealment piogiam to implement Yhe federal regulations Bouldei has had an approved pretreatment program smce January 1983 and ieceived an Environmental Protechon Agency (EPA) awaid for pietieatment excellencc m 1998 Over~ll objectives of the piogiam are desciibed as follows• • To prevent Lhe mtroduct~on of pollutants mto the City of Boulder waslewater collection and ireatment system that could mlerfere wrth wastewater plant operations • To pievent thc pase lhiough of untreated pollutants mto Boulder Cieek AG~NDA IT~M #5 PAG~ 3 To impiove recyclmg capabilities and beneficial use of biosolids To protect the geneial health and saYety of planl workers and downstrcam useis Chapter ll- 3 of the Bouldet Revised Code (B.R.C.) Establishes regulatoiy autborrty for the implementation of Boulder's pretrealment program Code ievisions aie developed as needed to assuie contmued compliance witb state and federal requiiements as well as effecrive management of the progiam. DISCUSSION / ANALYSIS: The local limits development process is an m-depth technical analysis of the characterislics of Boulder's wastewatei. It is currently bemg fmalized. This analysis is besY desciibed ae a polluCant mass balance for the wastewatei utihry system The study identifies pollutants of concern foi the utility based on EPA requuements. Pollutants identified foi ieview mciude ammoma, biochemical oxygen demand (BOD), arsenic, cadmium, chromium, copper, cyanide, uon, lead, meicuiy, molybdenum, manganese, mckel, selenmm, silver, and zmc The end result of the local limits evaluation is an allowable mass loading to the wastewater Ueatment plant for each pollulant of concein This pollutant loadmg is referred to as a local hmit and reflects the most strmgent limrtmg criteria facmg the wastewater system Limiling crrteria mclude NPDES peimrt hmris, Biosohds disposal limits, diinkmg watei limits, as well as chionic and acute watei quahty standatds. These local limits are mcorporated mto Industrial VJastewater Dischaige Permits which are issued to significant mdust~ial users EPA requires review of locallimits annually and ievision of local limits as necessary or when a new NPDES peimrt ~s issued to the wastewater treatment plant. The City of Bouldei's Wastewatei Trcatment Plant received a new NPDES permit in February 2003. Impacts to Industrial Users: Local hmits currently adopted m Bouldei Revised Code were developed and approved m 1994. Smce thal Yime Bouldei has grown, especially m the iesidential and commermal aieas Durmg the same period of rime, water quahty regulations have become mcieasmgly more stimgent. Finally, Boulder has developed more exactmg analytical data sets to betler desciibe wastewater consiituents. All of tliese factors together can change the outcome of a local hmrts process. There are currently twelve (12) permitted mdusliial users down from s~xteen (16) two yeais ago. Industrial users will be held to tightei sCandards for the polluCants copper, lead, mercury, mckel, and even iron In some cases this will mean that industues with historical data showmg background levels of a given pollulant may be iequired to stay withm Lhe background level. In othei cases specific permrt hmits will be idendfied that may requiie addidonal ireatment equ~pment purchases or other control stiategies. AG~NDA ITCM #5 PAG~ 4 One such mdustrial user is thc Boulder Reservou Watei Ticatmcnt Facilrty This facihly is curiently in the plamm~g slage to treat onsite all or part of thc waste residuals that bave historically been diechatged to the wastewater trea~ment plant. Allocat~on of pollutant contiibutions to each peiirutted industual usei has not yet been fmahzed Staff is activcly workmg on thts poition of the loeal hmits pro~ect. Preheatment staff is commiried to suppoiting the busmess commumty through appiopiiate environmental iegulation. Pretreatment staff strive to develop and allocate local lnnits lbat are pioteclive of Bouidei's wastewater tcealment plant bul do not cause undue l~aidship on the ~ egulaled commumCy Industry/Public Commenl Opportunities: Pretreatment staff mlends to provide oppoituruties for comment and discussion by hostmg a meehng for permitted industiial users and other mlerested parties This meetmg will be held at the Waslewater Tieatment Plant during lbe week of November 1Q 2003. Addifionally, staff will meet mdividually with each permitted uset impacted. The pielreatment Web sils will be updated wrth local hmits development materials. All mterested pai lies will be made aware of the WRAB public meetmg to be held on November 17, 2003 via publicaCion of'the meeting m the Daily Caineta Al this meeting, fmalized proposed code changes will be presented along wrth specific mformatron on impacts to permitted industries There will also be an opportamty foi the pubhc and WRAB to gam a mora m-depth understandmg of the loeal limils devclopment piocess Attachments: Timehne foi Local Limits Evaluation AG~NDA IT~M #5 PAGE 5 Gity af Boulder - IPT local Limi~s Eva[u~tion ; ~ 41, - <f3~ Prelimmary DaFa Coltect~on H~A 6ocume N Renew SIU Oata Rewtew 3U Waste Suney Reurew NPDES Permi Revieu* Stream Infa Rav3ew Apr 1, 2003 an5•5n5 Deveiopmeni ut Sampting F9an & Preparyiiort for Samplitzg . 5!9 5 - G/15 . fnfluent Stan . DataAnalys~s EPA~lO 8 fnr ' : IowerMDCs i a: y..t~w~~K~.~'c4^s"~~i.»....u`~$M~~t.t~i£t> 5ft5 • 7A7 Sampimg InflueM Efiuent B,asai~as an •sns sns-~nns 70/t5•ttf95 DamesUC Devetopmentnf OrdinanceMud~ca4on DraflSuBmffied Commerc~al Techmca0y Based Attorney Reaiew to EPA Hauled Waste Lvcal limits 11 ~ i - Today 75 Final EPASuhmrttal & Publ~c Nohce Finai CQPHE BubmRtal 11fl5-itt \ YvRAB Renew ~ Crty Councd Apprwal i ._.~ zn Locat Limds Effearve Feb 1 2004 Industry and SYakehokier Pubko Meetmg on Nwember 13, ~Q.13